美国财政部-2021美国税收计划报告（英文）-2021.4-19页_557kb

Summary of the Made in America Tax Plan

Core Content

The Made in America Tax Plan is a comprehensive corporate tax reform proposal by President Biden, designed to enhance the competitiveness of U.S. companies and workers by addressing long-standing flaws in the current tax system. The plan aims to reverse the trend of declining corporate tax revenues, reduce profit shifting and offshoring incentives, and promote clean energy production.

Main Objectives

• Increase corporate tax revenue to fund the American Jobs Plan, which includes investments in infrastructure, research, and manufacturing.
• Level the playing field between U.S. and foreign multinational corporations by reducing incentives to offshore profits and investment.
• Promote a fairer tax system that rewards labor and reduces inequality.
• Encourage clean energy production by eliminating fossil fuel subsidies and introducing tax incentives for sustainable technologies.
• End the "race to the bottom" in global corporate tax rates by promoting international cooperation on minimum tax rules.

Key Reforms

1. Tax Rate Increase

• The corporate income tax rate will be raised from 21% to 28%, aligning it more closely with historical and international norms.
• This increase is intended to generate more revenue while being paired with reforms that encourage productive investment.

2. Strengthening the Global Minimum Tax

• The plan introduces a country-by-country minimum tax to curb profit shifting by U.S. multinationals.
• It eliminates the tax exemption for the first 10% return on foreign tangible assets, thereby reducing incentives to offshore profits.
• The GILTI (Global Intangible Low-Taxed Income) minimum tax will be calculated on a per-country basis, increasing the rate to 21%, which is three-quarters of the new 28% corporate tax rate.

3. Eliminating Incentives for Offshoring

• The plan repeals the FDII (Foreign-Derived Intangible Income) deduction, which previously rewarded companies for shifting profits abroad.
• It also disallows deductions for the offshoring of production and introduces strong guardrails against corporate inversions.

4. Reforming the BEAT (Base Erosion and Anti-Abuse Tax)

• The BEAT is replaced with the SHIELD (Stopping Harmful Inversions and Ending Low-tax Developments), which denies U.S. tax deductions for payments to related parties in low-tax jurisdictions.
• SHIELD is tied to the global minimum tax rate agreed upon in international negotiations, with a default trigger based on the modified GILTI rate if no agreement is reached.

5. Ending Fossil Fuel Subsidies

• The plan phases out subsidies for oil, gas, and coal producers, which have distorted the energy market and reduced incentives for clean energy.
• It introduces new tax incentives for clean energy production and investments, supporting the transition to sustainable technologies.

6. Enhancing Tax Enforcement

• The plan increases IRS resources to improve corporate tax compliance and audit rates, reversing the trend of reduced enforcement.
• It aims to ensure that large corporations pay their fair share, particularly those with significant discrepancies between reported income to shareholders and the IRS.

Economic Context and Data

• Current U.S. corporate tax rate: 21%, but the effective tax rate on U.S. multinationals is only 7.8%, due to profit shifting and tax preferences.
• Corporate tax revenue as a share of GDP: Has dropped from 2% before the TCJA to 1% since its enactment, significantly below the OECD average of 3%.
• Corporate profits as a share of GDP: At 9.7% (2005–2019), the highest in U.S. history, while corporate tax revenue remains low.
• Profit shifting: U.S. multinationals have shifted 61% of their foreign income to tax havens, with Bermuda alone accounting for 10% of all reported U.S. multinational foreign profits.

Fairness and Inequality

• The labor share of national income has declined, while capital income has increased, contributing to income inequality.
• The U.S. corporate tax now raises less than 10% of federal revenue, while labor taxes account for over 80%.
• The plan aims to reverse this trend by making the tax system more progressive and labor-friendly.

Global Tax Coordination

• The U.S. has been part of a global race to the bottom, with OECD corporate tax rates falling from 32.2% in 2000 to 23.3% in 2020.
• The plan supports a global minimum tax agreement through the OECD/G20 Inclusive Framework, to prevent tax competition and ensure that all multinational corporations contribute fairly to the U.S. tax base.

Conclusion

The Made in America Tax Plan is a strategic effort to reform the U.S. corporate tax system by aligning it with international standards, reducing profit shifting, and promoting domestic investment and clean energy. It is designed to raise substantial revenue, level the playing field for U.S. companies, and build a more equitable and competitive economy for American workers and businesses.